Environmental and Social Risk Policies

In March 2013, ING has made its Environmental and Social Risk (ESR) Framework available online. The ESR framework involves the application of high environmental and social standards in our operations to mitigate risks, addressing issues like human rights, biodiversity and ethical dilemmas.

ING has applied its ESR policies to its business activities since 2003. The publication of the ESR framework followed an extensive review of the framework to reflect emerging best practices and to strengthen its implementation in the organisation. We have further updated our policies since and continue to do so to apply guidance on key sectors and how to how assess risks.



Client due diligence is a routine part of ING’s ‘on-boarding’ process. This means we check that the client and its activities are in line with ING’s Values and our ESR framework.

The ESR framework itself consists of several policies:

  • Human rights and environmental management
  • Exclusion
  • Sector specific.


Exclusion policy

ING will not finance activities or do business with companies or organisations where the majority of activities relate to excluded activities. See the Environmental and Social Risk framework (PDF, 260 kB) for the list of exclusion policies.

An example of an excluded activity is the trade of endangered animals. ING will not engage in transactions that are directly linked to animal trades or clients supporting animal trades, involving great apes, or endangered plants and species as defined in CITES Appendix 1 and the IUCN Red List, to be used for commercial purposes. Furthermore, ING refrains from business engagements with companies that are directly involved in animals testing for non-medical purposes and methods that can be considered degrading or unethical are like those not contemplated under best industry practices like the 3R’s approach (Replacements, Reduction and Refinement) or Association for Assessment and Accreditation of Laboratory Animal Care or AAALAC International accreditation.


Sector-specific policy

Some industry sectors are more likely to be associated with environmental and social risk than others. The cost of failing to manage these impacts is high. Therefore, ING has identified sectors where additional due diligence is required:

  • Chemicals
  • Energy (oil and gas, power generation)
  • Forestry and agricommodities
  • Manufacturing
  • Mining and metals.

Clients operating in these sectors – and each of their transactions – are assessed against industry standards and best practices on the management of environmental and social issues. When financing projects, ING also applies the Equator Principles: an internationally recognised credit risk management framework for project finance transactions.


Restrictive list

In order to ensure the ESR Framework can be applied across all its activities, ING has developed an ESR restrictive list of non-eligible companies. This list is used across the Group to ensure we don’t do business with companies who do not uphold our ING Values and ESR policies.


Serving our customers better

Implementing our ESR standards over the years has helped us serve our customers better. The framework can help our clients strengthen their overall risk profile. To help achieve this, a dedicated Environmental and Social Risk team advises relationship managers, the credit committee, senior management and our clients on business transactions with potential environmental or social sensitivities.